We recommend that the Director of the Office of Disaster Recovery require the State to develop and implement a policy to identify ownership and primary residency earlier in the review process and potential red flags in documentation.

We recommend that the Director of the Office of Disaster Recovery require the State to document and support its decision regarding duplication of benefits and income verification for additional owners of the property under an application.

We recommend that the Deputy Assistant Secretary instruct the Virgin Islands Housing Finance Authority to develop and implement procedures, including financial controls, to enhance its tracking of payments made with CDBG-DR funds and payments made with FEMA funds to ensure that payments are not made for the same invoices, match requirements are not exceeded before closeout, and a thorough review is conducted for award increases and cost reasonableness.

We recommend that the Deputy Assistant Secretary instruct the Virgin Islands Housing Finance Authority to enforce its subrecipient agreement requirement to submit monthly status reports.

We recommend that the Deputy Assistant Secretary instruct the Virgin Islands Housing Finance Authority to develop and implement procedures to ensure that all Match Program activities are monitored, and guidance is provided to its Match Program recipients.

We recommend that the Deputy Assistant Secretary instruct the Virgin Islands Housing Finance Authority to develop and implement detailed policies and procedures to guide staff in reporting performance outcomes in the QPR and on its disaster recovery website.

We recommend that the Deputy Assistant Secretary instruct the Virgin Islands Housing Finance Authority to revise its policies and procedures to include requirements to document its basis for activities’ meeting the national objective, including the rationale for the service area used and a list of acceptable documents to support that the area was primarily residential for the low- and moderate- income area benefit national objective.

We recommend that the Deputy Assistant Secretary instruct the Virgin Islands Housing Finance Authority to conduct training for Authority staff on the newly developed or revised policies and procedures

We recommend that the Deputy Assistant Secretary work with the Authority to assess the risk of potential improper payment for projects PW273 and PW100 and vouchers 576322, 583423, and 578761.

We recommend that the Deputy Assistant Secretary require HUD program staff to provide technical assistance to the Authority to address deficiencies noted throughout the audit report.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement monitoring policies and detailed procedures to guide the Authority’s CMU staff in assessing activity performance to meet the subrecipient monitoring requirements and establish written performance metrics to progressively achieve the performance outcome for those activities the Authority administers.

We recommend that the Deputy Assistant Secretary instruct the Authority to revise subrecipient agreements to include performance metrics and milestones tailored to the activity in sufficient detail to enable the Authority to collect information to effectively assess the activity’s performance.

We recommend that the Deputy Assistant Secretary instruct the Authority to revise the monthly status report template to allow the subrecipient to report its current progress against the established performance metrics.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop a tracking process to ensure that the Authority issues monitoring reports and receives responses to these reports within the timeframe required by its policy. This process should also include a referral to management when the timeframe requirements are not met.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop detailed procedures to ensure that the corrective action tracking process is consistently followed to ensure proper resolution.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement policies and detailed procedures to establish the CMU’s responsibilities related to verifying that the CDBG-DR activity meets the stated national objective.

We recommend that the Deputy Assistant Secretary instruct the Authority to develop and implement policies and detailed procedures to identify the risk analysis process for monitoring all CDBG-DR-funded activities during the course of the activity and require that the monitoring files document the basis for why an activity is or is not monitored.

We recommend that the Deputy Assistant Secretary instruct the Authority to train the CMU staff on the newly developed policies and procedures and obtain technical assistance from HUD as needed.

Establish an improper payment council within HUD that consists of senior accountable officials from across the Department with a role in the effort that would work to identify risks and challenges to compliance and identify solutions as a collaborative group.

Develop and complete a detailed plan and timeline for completing compliant PIH-TBRA and PBRA program estimates and ensure that the improper payment council prioritizes completion of the plan in time for fiscal year 2023 reporting.